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Where under any provision of this Convention a partnership is entitled, as a resident of a Contracting State, to exemption from tax or is not subject to tax in the other Contracting State on any income or capital gains, that provision shall not be construed as restricting the right of that other Contracting State to tax any member of the partnership who is a resident of that other Contracting State on his share of such income or capital gains; but any such income or gains shall be treated for the purposes of Article 22 of this Convention as income or gains from sources in the first mentioned Contracting State.
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